Case 1:19-cv-03377 Document1 Filed 04/16/19 Page 26 of 28 95. Dershowitz’s false statements directly stated and also implied that in speaking out against sex trafficking Roberts acted with fraud, dishonesty, and unfitness for the task. Dershowitz’s false statements directly and indirectly assert that Roberts lied about being sexually trafficked and abused by Epstein and having sex with Dershowitz, and that Roberts committed the crimes of perjury and extortion. Dershowitz’s false statements were reasonably understood by many persons who read his statements as conveying that specific intention and meaning. 96. Dershowitz’s false statements were reasonably understood by many persons who read those statements as making specific factual claims that Roberts was lying about specific facts, and committed the crimes of perjury and extortion. 97. Dershowitz specifically directed his false statements at Roberts’ true public description of factual events, and many persons who read Dershowitz’s statements reasonably understood that those statements referred directly to Roberts’ account of the abuse she suffered at the hands of Epstein and Dershowitz. 98. Dershowitz and Epstein intended Dershowitz’s false statements to be widely published and disseminated on television, through newspapers, by word of mouth, and on the internet. As intended by Dershowitz and Epstein, Dershowitz’s statements were published and disseminated around the world. 99. Dershowitz made his false statements on behalf of himself and Epstein in reckless disregard of their truth or falsity and with malicious intent to destroy Roberts’s reputation and credibility; to prevent her from further disseminating her life story; and to cause persons hearing or reading Roberts’s descriptions of truthful facts to disbelieve her entirely. Dershowitz made his false statements on behalf of himself and Epstein wantonly and with the specific intent to maliciously damage Roberts’s good name and reputation in a way that w